Structuring Joint Ventures Between Private Equity and Athletes or Entertainers

To understand the importance of marketing, one needs to look no further than Augusta, Jordan Spieth, and Under Armour. In January 2015, Under Armour signed Spieth to a ten-year endorsement deal. Only four months later, he won the Masters in Augusta, Georgia. By some estimates, Spieth was wearing 16 Under Armour logos on his clothes in the final round. Regardless of the number of logos, Spieth's victory at Augusta was a win for both Spieth and Under Armour. Just like Under Armour, businesses often try to capitalize on the appeal of celebrity by engaging notable figures to promote their products or services. While there are many mechanisms through which a business may secure such an endorsement, this article addresses the seemingly confusing federal income tax rules surrounding the transfer of the exclusive right to use a celebrity's name and likeness for a limited time, in exchange for a partnership interest.